Privacy notice

This notice explains which personal data EasyLPD processes, why, for how long and to whom it entrusts them. It applies to the website easylpd.ch (and easydsg.ch), to the platform at /app and to the pages the platform makes available to external people (training portal, public page of an organisation, questionnaire for vendors, verification of a certificate, signature of a document).

The Swiss Federal Act on Data Protection (FADP) applies and, where its conditions are met, the General Data Protection Regulation of the European Union (GDPR).

1. Who processes the data

Controller

Advisorn GmbH, Via Valdani 2, 6830 Chiasso, Switzerland E-mail: contact@easylpd.ch

Advisorn GmbH is the controller for the data of those who visit the website, open an account or purchase a subscription or consulting.

When EasyLPD is a processor

Everything a customer organisation enters into the platform about other people (staff, clients, vendors, people exercising a right, signers of a document) is processed by Advisorn GmbH on behalf of that organisation, which remains its controller. In these cases the organisation's privacy notice applies, and requests must be addressed to it: we forward them if they reach us.

2. Which data we process and why

2.1 Visiting the website

The website uses no tracking cookies and no third-party analytics services. Visits to the public pages are counted by us:

• page viewed, language, referring website, any campaign tags of the link, seconds spent on the page;
• country and canton or region, type of device, family of the browser and of the operating system (never the full identifier of the browser);
• a code derived from the IP address and the browser, different every day, which serves only to count the visitors of one day and does not allow a person to be recognised from one day to the next;
• of the IP address only the network, i.e. the address without its last part, erased after 30 days. The full address is not stored.

Anyone who has enabled "Global Privacy Control" or "Do Not Track" in the browser is not counted at all. Requests from automated programs (search engines, artificial intelligence services, other bots) are recorded with the name the program declares.

Purpose: to understand which pages are useful and where visitors come from. Legal basis: our legitimate interest in improving the website with data that do not identify a person.

Status page. The service status page (status.easylpd.ch), which the "Service status" link points to, is run by Better Stack, Inc., not by us. That page loads Better Stack's own tools, among them Google Ads (Google), which may use cookies and receive the IP address and browser data of whoever opens it; Better Stack's privacy policy applies to that data. The rest of the website loads nothing from Better Stack or Google.

2.2 Self-assessment without an account

The answers of the free self-assessment stay in the browser of the person completing it. They reach our servers only if the person opens an account and chooses to take them along. The same holds for the public MCP server (https://easylpd.ch/api/mcp), through which an AI assistant uses the self-assessment and our guides: the questions and answers it receives are not stored.

2.3 Account

• name, e-mail address, password (stored only in unreadable form), confirmation status of the address;
• if enabled: two-step verification, passkeys, sign-in with Google or Microsoft (from these we receive only name and e-mail address);
• sign-in sessions: date, IP address and browser, to protect the account and allow them to be ended;
• sign-in attempts, to limit abuse;
• devices that have requested push notifications.
• the version of the general terms accepted when the account was opened, with the date.

Purpose: to provide the service and protect it. Legal basis: the performance of the contract and our legitimate interest in security.

Use of the platform: for each day, which sections (for example the register or the documents) you opened and how many pages, never what you read or write there. Only EasyLPD's staff see it, to understand what is useful and what to improve. Legal basis: our legitimate interest in improving the service.

2.4 Content of the platform

Data of the organisation, answers of the assessments, action plan, record of processing activities, vendors, appointments (name, e-mail address and role of the people appointed), consents and acknowledgements (name and e-mail address of the signer, the answers, the day and the family of the browser and system used to sign, never the IP address), documents and uploaded files, breaches, impact assessments, data subject requests, tasks, change log, notifications. This content may concern third parties: we process it on behalf of the customer organisation (point 1).

Advisorn staff do not read a customer's content. Only a consultant can do so, read-only, after the customer has granted access for a limited period; every consultation is recorded in the customer's change log, and the customer can revoke access at any time.

2.5 Subscription, invoices and consulting

• billing data (company name, address, VAT number), subscription and invoices;
• card payments are handled by Stripe: we neither see nor store card data;
• consulting requests and reports to technical support, with the files the customer attaches to them (stored in Zurich like the other files and visible to the customer and to Advisorn), and hours provided;
• the booking of an introductory call: it takes place on the Cal.com page, to which our buttons lead with a simple link (nothing from Cal.com is embedded on our website). Cal.com receives name, e-mail address and what is written in the booking, and passes them to us to organise the call.

Legal basis: the performance of the contract and the legal obligations on the retention of accounting records.

2.6 Signing documents

Signature in the platform. When a member signs a document we store name, e-mail address, date and time, the way they confirmed their identity and the hash (SHA-256) of the signed PDF.

Consents and acknowledgements. An organisation can ask clients, parents or staff to confirm that they have read a document or to give consent. The signer receives from us by e-mail the link and a 6-digit code; no account is needed and we use no cookies. For the organisation we store the signed text, the answers, name and e-mail address, the day and the family of the browser and system. These data stay in Zurich and do not go to BA Scribe.

Signature by people without an account. An organisation can ask an external person for a signature through BA Scribe, a service of Aletheia Tech Ltd (United Kingdom). To BA Scribe we transmit the signer's name and e-mail address, and the title and hash of the document. The document is not transmitted: it stays in our storage in Zurich and the signer's browser reads it from there. During signing BA Scribe also records the signer's IP address and browser, and the time of the verification of the e-mail address, of the consent and of the signature. These data appear in the proof of signature and in the certificate that BA Scribe issues and that we keep together with the document, so that the organisation can prove the signature. BA Scribe deletes the personal data of signers 30 days after the request is closed.

In both cases this is a simple electronic signature, not a qualified electronic signature.

2.7 Proofs of existence

For final documents, signed copies, proofs of signature, training certificates and exports of the dossier we calculate the SHA-256 hash of the file and have it anchored on public blockchains (Polygon and Bitcoin) through BA Stamp, a service of Aletheia Tech Ltd. To BA Stamp we transmit only the hash and a file name made of the title of the document and the version, never the content and never the name of a person. A hash does not allow the content to be traced back. What is recorded on a public blockchain cannot be deleted.

2.8 Pages for external people

• Training portal: name and e-mail address given by the staff member, courses completed, score, confirmations of having read documents. If the employer uploads it, also the list of staff (name and e-mail address), used only to see who has not yet completed a course and to send a reminder.
• Verification of a certificate: whoever has the code printed on the certificate sees name, organisation, course, score and validity. Certificates cannot be listed or searched.
• Public page and request form: what the person writes in the form reaches the organisation they are addressing.
• Questionnaire for vendors: the answers reach the organisation that sent it.

For these pages the controller is the organisation that uses them.

2.9 E-mails and notifications

We send only service e-mails: confirmation of the address, password recovery, invitations, deadline reminders, notices, invoices. A notice says that something has arrived and links to the platform: the data stay behind the sign-in, with the exception of the invoice, attached as a PDF. E-mails are sent through Brevo, which counts their opens and clicks anonymously, without linking them to the person receiving them: we do not use these counts. Push notifications, if enabled, pass encrypted through the service of the maker of the browser or device (Apple, Google, Mozilla, Microsoft), which learns only that the device has received a message from us.

2.10 Contact form

Whoever writes to us from the contact page entrusts us with name, e-mail address, the organisation if given, the subject and the message. They reach us by e-mail through Brevo and we keep them in the mailbox as long as needed to reply and to follow up on the request. Legal basis: the interest in replying to those who contact us.

3. Cookies and browser storage

We use only what is needed to make the service work:

• a session cookie, when signing in to the platform;
• a cookie with the language chosen;
• on the training portal, a cookie that confirms the staff member's identity for 12 hours after the code received by e-mail;
• in the browser's storage: the light or dark theme, the state of the sidebar and, before an account is opened, the answers of the self-assessment.

No advertising or profiling cookies. For this reason we do not ask for consent: a short notice on the website explains it and links to the cookie page. Names and durations are on the cookie page.

4. Where the data are and who receives them

Customers' data and their backups are stored in Switzerland: the database in Zurich, uploaded files in Zurich, encrypted backups in Geneva. The application code runs in Frankfurt (Germany).

We use these providers, to which we entrust only the data needed for their task:

For signing, BA Scribe in turn uses providers for the database, for running the service and for sending the verification code by e-mail.

Transfers abroad. According to the Federal Council and the European Commission, the European Union and the United Kingdom provide adequate data protection. Data are transferred to the United States only to companies certified under the Data Privacy Framework or on the basis of the standard contractual clauses.

We do not sell data and do not disclose them to others, except where the law obliges us to.

5. For how long

6. Security

Encrypted connections, passwords stored in unreadable form, two-step verification and passkeys available to every user, data separated by organisation, backups encrypted with a key that is not on the servers, change log for every organisation. Uploaded files are not scanned for malicious software.

7. Your rights

You can ask to know which data we process about you, to receive a copy of them, to have them corrected or deleted, to restrict or object to their processing and to receive them in a reusable format. Those with an account find on the "Account" page the export of the organisation's data and the deletion of the organisation and of the account.

Write to contact@easylpd.ch: we reply within 30 days. If your data were entered by a customer organisation, contact that organisation.

You can contact the Federal Data Protection and Information Commissioner (FDPIC), www.edoeb.admin.ch, or, if the GDPR applies, the supervisory authority of your country.

8. Automated decisions

The score of the self-assessment is calculated automatically from the answers and serves only as guidance for the organisation: it produces no legal effects on a person. We do not carry out profiling.

9. Changes

We update this notice when the way we process data changes. The date of the last update is shown at the top.